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• <br /> 5. Require and keep only the kinds of customer information that are necessary for utility <br /> purposes. <br /> VI. PROGRAM UPDATES <br /> This Program will be periodically reviewed and updated to reflect changes in risks to <br /> customers and the soundness of the Utility from Identity Theft. At least one time per year, the <br /> Program Administrator will consider the Utility's experiences with Identity Theft situations, <br /> changes in Identity Theft methods, changes in Identity Theft detection and prevention methods, <br /> changes in types of accounts the NUPUC maintains and changes in the NUPUC's business <br /> arrangements with other entities. After considering these factors, the Program Administrator will <br /> determine whether changes to the Program, including the listing of Red Flags, are warranted. If <br /> warranted, the Program Administrator will update the Program and communicate these changes <br /> to the NUPUC for approval. <br /> VII. PROGRAM ADMINISTRATION. <br /> A. Oversight <br /> Responsibility for developing, implementing and updating this Program lies with an <br /> Identity Theft Committee for the NUPUC. The Committee is headed by a Program Administrator <br /> • who is the Finance Director\City Clerk-Treasurer. Two or more other individuals appointed by <br /> the Program Administrator comprise the remainder of the committee membership. The Program <br /> Administrator will be responsible for the Program administration, for ensuring appropriate <br /> training of Utility staff on the Program, for reviewing any staff reports regarding the detection of <br /> Red Flags and the steps for preventing and mitigating Identity Theft, determining which steps of <br /> prevention and mitigation should be taken in particular circumstances and considering periodic <br /> changes to the Program. <br /> B. Staff Training and Reports tAt 1D I/la <br /> Utility staff responsible for implementing the Program shall be trained either by or under <br /> the direction of the Program Administrator in the detection of Red Flags, and the responsive <br /> steps to be taken when a Red Flag is detected. <br /> When an instance of identity theft is detected, the staff member(s) involved shall prepare a <br /> narrative of what occurred and the steps taken in the process of resolving the problem. <br /> C. Service Provider Arrangements <br /> In the event the Utility engages a third party service provider to perform an activity in <br /> • connection with one or more accounts, the Utility will take the following steps to ensure the <br /> 6 <br />